MITSUBISHI MOTORS NORTH AMERICA

SUMMARYInformation Collected by MMNA

If you use the Connected Vehicle Services, MMNA may collect information about you, including your contact information, information about your vehicle and your use of your vehicle, information from your mobile device and your use of the My MITSUBISHI CONNECT mobile application, information about your communications with Customer Care, and information collected by the Owner Portal website. Information collection may also vary depending on the type of Service or Subscription Package you are using.

We may collect information from a variety of sources, including from you directly, from your vehicle, from your use of the Mobile App, from your use of the Owner Portal, from your communications with Customer Care, and from third party sources.

How MMNA Uses and Shares Collected Data

We may use information we collect from you to provide you with the Services, to provide customer and vehicle support and service, to communicate with you about your account or your vehicle, to offer you products or services, and for other purposes.

We may share certain information we collect from you (including Personal Information) with our third parties acting on our behalf, with emergency service providers in order to deliver related services, with third parties in connection with financing your vehicle, and with other third parties.

We may share aggregated data (which excludes your Personal Information) with our business partners and other third parties.

Correcting Personal Information and Opting Out

You may opt out of receiving certain communications from MMNA, such as communications regarding marketing or promotions, by indicating your preference through the Owner Portal, contacting Customer Care, through the Mobile App, and through other means.

If you would prefer to not have MMNA collect any Vehicle Data from your vehicle, you will need to contact Customer Care and request that your vehicle’s telematics-enabling Device be deactivated and that the Vehicle Data Collection be stopped. This will also disable your ability to receive any Services.

Your Obligations

It is your responsibility to tell your vehicle occupants and users about the Services and how they work, what data may be collected (e.g., collection of geolocation data) and how that data may be shared, and what the limitations of the Services are (e.g., they may not work in remote areas).

I. INTRODUCTION

Mitsubishi Motors North America (“MMNA” or “we”) offers those who purchase certain models of Mitsubishi vehicles the ability to receive Connected Vehicle Services (“Services”). This Privacy Statement explains how personal information about you is collected, used, and disclosed by MMNA with respect to the Services, including by the telematics device on your vehicle (the “Device”), through the online MMNA Connected Vehicle Services website for customers (the “Owner Portal”), through the My MITSUBISHI CONNECT mobile application (the “Mobile App”), through the MMNA Connected Vehicle Services customer care agent at (888) 564-1411 (“Customer Care”), and through dealership records provided to MMNA in connection with the Services. This Privacy Statement does not apply to vehicles, products and services that are unrelated to the Services, that are not offered by MMNA or that do not otherwise link to or incorporate this Privacy Statement.

For more information about the types of Services or Subscription Packages that are offered in connection with the Connected Vehicle Services, please review the MMNA Connected Vehicle Services website.

YOU MUST BE AWARE THAT DEFAULT VEHICLE DATA (AS DEFINED IN THE TERMS AND CONDITIONS, WHICH INCLUDES YOUR GEOLOCATION INFORMATION, ODOMETER VALUE, VEHICLE ERRORS AND OTHER VEHICLE-RELATED DATA) WILL BE COLLECTED, USED, DISCLOSED AND SHARED BY MMNA IN ACCORDANCE WITH THIS PRIVACY STATEMENT, THE TERMS AND CONDITIONS, AND U.S. LAWS, RULES AND REGULATIONS, INCLUDING FOR MARKETING PURPOSES TO OFFER PRODUCTS AND OTHER SERVICES TO YOU. THIS DATA MAY START BEING COLLECTED IMMEDIATELY UPON YOUR PURCHASE OR LEASE OF YOUR VEHICLE FROM THE DEALER. YOU WERE NOTIFIED OF AND CONSENTED TO THIS COLLECTION, USE, DISCLOSURE AND SHARING AT YOUR TIME OF VEHICLE PURCHASE OR LEASE. THIS DATA MAY BE COLLECTED FROM YOUR VEHICLE, EVEN IF YOU DO NOT ACTIVATE THE CONNECTED VEHICLE SERVICES OR PURCHASE A SUBSCRIPTION SERVICES PACKAGE OR IF YOUR SUBSCRIPTION, TRIAL OR RENEWAL PERIOD HAS EXPIRED. IF YOU DO NOT WANT THIS DATA TO BE COLLECTED, CONTACT CUSTOMER CARE TO DEACTIVATE YOUR VEHICLE’S TELEMATICS-ENABLING DEVICE AND REQUEST THAT THIS VEHICLE DATA COLLECTION BE STOPPED. UPON DEACTIVATION OF THE DEVICE, YOU WILL NO LONGER BE ABLE TO RECEIVE ANY SERVICES, AND ANY APPLICABLE SUBSCRIPTION SERVICE PACKAGE, INCLUDING ANY FREE “TRIAL” SUBSCRIPTION, PURSUANT TO WHICH YOU WERE RECEIVING THE SERVICES WILL IMMEDIATELY TERMINATE.

II. INFORMATION COLLECTED BY MMNA

1. GeneralTypes of Information Collected

We may collect the following types of information from you, your vehicle, and/or your devices (collectively, “Collected Data”) when you use of the Services, as described in this Section:

Personal Information: Personal Information includes your name, address, telephone number, date of birth, email address, information about the acquisition and financing of your vehicle, billing information (e.g., credit card number), personal preferences (e.g., opt-in preferences, language preferences), and other personal information about you. For purposes of this Privacy Statement, aggregated, de-identified or anonymized information, which includes data that is related to you but does not identify you specifically, is not considered to be Personal Information.

Access Information: Access Information is information that is collected automatically in connection with your use of the Owner Portal or Mobile App, and includes IP addresses, browser types, internet service providers (ISP), MAC address, device or session ID, referring/exit pages, operating systems, date/time stamps, your usage and activity on our Owner Portal (e.g., clickstream data), device type, log files, campaign engagement (e.g., clicking through campaign emails), and other access-related information. This information is gathered by certain tools and methods such as log files, cookies, web beacons, and embedded scripts. For more information about how we automatically collect some of this information, please see Section VII (Tracking and Analytics) below.

2. Information Collected by the Device/Vehicle

Depending on the type of Service or Subscription Package you are using, the following information may be collected:

Voice recordings of interactions with Customer Care and emergency personnel

6. Information Collected by Other Means

We may also collect Personal Information from you through other sources, including our affiliates, dealers, and other business associates in connection with the Services, such as dealership records and service repair order information. We may combine that with the information we collect directly from you. If we receive Personal Information from a third party source and/or if we combine the information we receive from these third party sources with your Personal Information, we will treat that information as Personal Information. We are not responsible for the accuracy of the information provided by third parties or how such third parties collect, use and share such information.

provide information about our products and send you related information, including confirmations, brochures, technical notices, updates, security alerts and support and administrative messages;

notify you of the closest Mitsubishi dealer;

process and deliver sweepstakes, contests and promotions;

respond to comments, questions, or requests for information and provide customer service;

communicate with you about our vehicles, products, services, information, contests, promotions, rewards, special offers, upcoming events and other news about MMNA and our selected partners we think will be of interest to you;

monitor and analyze trends, usage and activities;

develop new products and services, including autonomous vehicle and car-sharing products and services;

provide customer and vehicle support and service (for example, recall information, servicing and maintenance or warranty service);

verify eligibility for vehicle purchase or incentive programs;

comply with legal, regulatory or contractual requirements;

generate site analytics to improve our website and the user experience;

link or combine with Personal Information we get from third parties to help understand your needs and provide you with better service;

conduct research and analysis, including focus groups and surveys, on the Owner Portal and other MMNA websites, applications, products and services; and

prevent fraudulent transactions and monitor against threats.

In addition, we may share the Collected Data:

with third parties in connection with financing your vehicle;

with emergency service providers, such as law enforcement, roadside assistance providers, and ambulance providers, in order to deliver related services (for example, Stolen Vehicle Assistance Services);

with certain unaffiliated third parties to provide select products and services to you;

when you give us your consent to do so, including if we notify you on the Owner Portal or Mobile App that the information you provide will be shared in a particular manner and you provide such information;

with vendors, contractors, consultants and other service providers who are working on our behalf and need access to your information to carry out their work for us;

to the maximum extent permitted by applicable law, to (i) comply with laws or to respond to lawful subpoenas, government inquiries, litigation, dispute resolution, requests and legal process, or if in our good faith opinion such disclosure is required or permitted by law; (ii) at the request of governmental authorities conducting an investigation; (iii) to protect our rights, security, safety and property and those of our agents, customers and others, including to enforce our agreements, policies and Terms and Conditions; (iv) to detect, investigate and prevent fraud; (v) to conduct screening to ensure you are not on any government list of restricted parties; or (vi) in an emergency to protect MMNA and the safety of our customers, employees or any third party;

if we believe your actions are inconsistent with our user agreements or policies, including our Terms and Conditions;

to the maximum extent permitted by applicable law, we may also use IP addresses, mobile device identifiers or any other information we collect to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you;

in connection with, or during negotiations of, any merger, sale of company assets (including a liquidation, realization, foreclosure or repossession), restructuring, reorganization, financing, disposal, conveyance, transfer lease, or any other type of acquisition of all or a portion of our assets or business to another company; and

for a purpose disclosed elsewhere in this Privacy Statement, or at the time you provide.

2. Use and Sharing of Information Collected by the Device/Vehicle

Specifically, with respect to the information collected in connection with the Device, we may use the information in the following ways, depending on the type of Service or Subscription Package you are using:

To provide the Services and support to you;

To monitor, measure and report on vehicle and user engagement and usage;

To communicate relevant message based on pattern and usage of Services;

To inform you of various features and Services, including to encourage use of certain features;

For marketing purposes, to offer other goods and services to you;

To solicit your feedback on the vehicle and the Services; and

To generate site analytics to improve our website and the user experience.

In addition, we may share such information in the following ways:

For Services requiring emergency responders, roadside assistance or other third party providers, Vehicle Geolocation Information will be shared with such third party providers;

MMNA’s affiliates, parents and subsidiaries; and

MMNA’s dealer network, for vehicle servicing and for their own marketing purposes.

3. Use and Sharing of Aggregated, De-Identified or Anonymized Information

We may aggregate, de-identify or anonymize the Collected Data so that it does not identify you or your vehicle specifically. We may use such aggregated, de-identified or anonymized data or share it with third parties for any legitimate business purpose.

IV. REVIEW AND CORRECTION OF PERSONAL INFORMATION; RETENTION

You may review and update any Personal Information that you provided to MMNA during your registration process by logging into the Owner Portal or the Mobile App.

We will retain Collected Data as needed for legitimate business purpose in accordance with our data retention policies or for regulatory requirements. After the Collected Data is no longer needed for these purposes, we will store it in de-identified form and/or delete it.

V. CHOICE; OPTING-OUT

1. Transmission of Vehicle Data

If you would prefer to not have MMNA collect any Vehicle Data from your vehicle, you will need to contact Customer Care and request that your vehicle’s telematics-enabling Device be deactivated and that the Vehicle Data Collection be stopped. Upon deactivation of the Device, you will no longer be able to receive any Services, and any applicable Subscription Service Package, including any Trial Subscriptions, pursuant to which you were receiving Services will immediately terminate.

2. Marketing Communications

From time to time, you may also receive mail, email, text message and telephone communications from MMNA, including communications regarding product information, marketing or promotions, research, and/or other topics. To contact you, MMNA may use the information you provide to us, including email, direct (postal) mail, mobile number or other telephone phone. You may, at any time, inform us that you do not want MMNA to contact you with marketing communications using certain or all methods by (1) indicating your preference through MMNA’s communication preferences page, available at https://www.mitsubishicars.com/preferences, (2) contacting Customer Care, (3) indicating your preference through the Owner Portal, or (4) managing your email and text alert notification preferences from within the Mobile App.

In addition, you may also opt-out of promotional email communications from MMNA by clicking on a link provided in the promotional email message. You may also opt-out of promotional text message communications from MMNA by texting MITSUSTOP from the mobile device that you have registered with MMNA. After opting-out, you will no longer receive marketing or promotional communications through the applicable method, but will continue to receive other messages, such as Remote Services notifications and specific information related to your use of the Services or vehicle (e.g., warranties, service reminders).

Note that deactivating your Device will not automatically opt-you out of receiving such marketing or promotional communications.

3. Service and Other Safety Notifications

Regardless of what may be said above, at the point of information collection, or your stated privacy preferences, MMNA reserves the right to contact you in the event of a service notification for your Device or vehicle (e.g., a recall notice), or to issue other notices concerning the safety of your vehicle.

VI. SAFEGUARDING YOUR INFORMATION

We take reasonable measures to help protect your Personal Information in an effort to prevent misuse and unauthorized access, disclosure and alteration. Although MMNA uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and MMNA cannot guarantee the security of your information collected from your vehicle or through the use by you of the Services.

When you visit the Owner Portal, you may be issued a “cookie,” which helps track your session while online. Cookies are small data files stored on your hard drive. Among other things, cookies help to make your website visit more relevant and personalized for you. We use cookies on the Owner Portal, including both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate the Owner Portal. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.

We use cookies to see which areas and features are popular and to count visits to the Owner Portal. Most browsers are initially set to accept cookies. If you would prefer, you may set your browser to refuse cookies or alert you when cookies are being sent; however, it is possible that some parts of the Owner Portal will not function properly if you do so and we may not be able to provide you with the most convenient or tailored experience.

3. Web Beacons

The Owner Portal and any communications sent by MMNA may contain electronic images (generally, single pixel “.gif’ images) called “web beacons.” These web beacons allow MMNA and third parties to monitor and collect certain information about the viewer of a web page, email message or other communication, such as the type of browser requesting the web beacon, the device identifier of the device the web beacon is sent to and the time the web beacon was viewed. Web beacons may be used to count unique users, visits and page views; monitor traffic and conversion patterns; personalize your experience when you visit the Owner Portal, including content you see; and determine whether or not messages were opened, links were clicked and/or notifications/offers were acted upon.

4. Embedded Scripts

An embedded script is programming code that is designed to collect information about your interactions with the Owner Portal. It is temporarily downloaded onto your computer from our web server or a third party with whom we work, is active only while you are connected to the Owner Portal, and is deleted or deactivated thereafter.

Information we automatically collect about you, such as how you interact with the Owner Portal, may be combined with your Personal Information. If we associate any such automatically-collected information with Personal Information about you, we will treat the combined information as Personal Information.

5. Do Not Track

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, MMNA currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

6. Analytics Services

We use Google Analytics and other service providers to provide analytics about the use of the Owner Portal and our other websites. Such third parties may be able to collect limited information about you, including through the use of cookies. We use Google Analytics to learn more about the types of users that visit the Owner Portal and to help improve the Owner Portal. For example, Google Analytics provides us with certain data regarding the demographics of the users that visit the Owner Portal. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/ . You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout/ or downloading the Google Analytics Opt-out Browser Add-on.

VIII. YOUR OBLIGATIONS

It is your sole responsibility to tell your vehicle occupants and users about the Services and how they work, what data may be collected (e.g., collection of geolocation data) and how that data may be shared, and what the limitations of the Services are (e.g., they may not work in remote areas). If you choose to activate features such as curfew, boundary or speed alerts, you have the obligation to explain that remote monitoring of the vehicle will be conducted using parameters that you set. You agree to make all vehicle occupants and users aware of this Privacy Statement and the privacy choices you have made.

If you sell, lease or otherwise transfer your vehicle directly to another person, it is your responsibility to notify such subsequent owner of the Services (including the Vehicle Data Collection and any other collection of data) and this Privacy Statement and the Terms and Conditions. In addition, prior to such transfer, you should delete all information (such as contacts and saved map addresses stored in the vehicle) from the vehicle and contact Customer Care to cancel your account. Any information you do not delete may be accessible to future users of the vehicle. Please refer to your Owner’s Manual for instructions on how to delete information from your vehicle’s system.

IX. CALIFORNIA PRIVACY RIGHTS

Under California’s Shine the Light law, Cal. Civ. Code § 1798.83, California residents have the right to request and obtain, once per year, information regarding MMNA’s disclosure of personal information to third parties (and, in some cases, affiliates) for their own direct marketing purposes. To request a list of the categories of information MMNA has shared, and the names and addresses of such third parties and affiliates, please send your request to:

Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

X. EXCLUSIONS

1. Children

The Services, including the Owner Portal and the Mobile App, are not intended for and are not targeted to children under the age of 13. Children under the age of 13, are not permitted to use the Services and should not send any information about themselves to us through the use of the Services. It is your sole responsibility to tell your vehicle occupants and users that the Services are not to be used by children.

We do not knowingly collect any Personal Information from children under the age of 13 and, if we learn that we have received information from a user under the age of 13, we will delete this information in accordance with the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and you believe that your child under the age of 13 has provided us with Personal Information without COPPA-required consent, please contact us at callcenterweb@mitsubishicars.com.

2. Third Party Links

The Owner Portal and Mobile App may contain links to third party websites and services, including but not limited to social media sites and applications. This Privacy Statement does not apply to the linked sites, and we do not control, nor are we responsible for, the content or privacy and security practices of those sites. Any Personal Information you provide to a linked site or service is provided directly to a third party and is subject to such third party’s privacy policy. We encourage you to learn more about such third party’s privacy and security practices and policies before providing any of your personal information.

3. Consent to Transfer Information

The Services are operated from within the United States. If you are located outside of the United States, and are accessing the Owner Portal or Mobile App or otherwise using the Services, please be aware that information we collect will be collected and stored in the United States. By using or accessing the Owner Portal or Mobile App, using the Services or providing us with any information through the Services, you consent to this transfer, processing and storage of your information in United States.

XI. CONTACT US

If you have any questions or concerns about this Privacy Statement, please contact MMNA by calling 1-888 MITSU2018 (1-888-648-7820), or emailing us at callcenterweb@mitsubishicars.com, or sending us a request at the address below:

XII. UPDATES TO PRIVACY STATEMENT

From time to time, we may update this Privacy Statement. If we do, we will note near the top of this page the date that any changes are made and/or when they become effective. If the changes being made are material, we may provide you with additional notice. Your inaction or continued use of the Services, including access to the Owner Portal, after any such updates or notices will tell us that you agree to these changes.